Quinones v. Donahoe

Filing 54

Joint Stipulation to continue non expert discovery and non dispositive motions deadlines; Order, signed by Magistrate Judge Erica P. Grosjean on 4/13/2016. (Discovery due by 5/9/2016; Non-Dispositive Motions filed by 5/9/2016) (Rosales, O)

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BENJAMIN B. WAGNER
United States Attorney
ALYSON A. BERG
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, California 93721
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant MEGAN BRENNAN, POSTMASTER
GENERAL, UNITED STATES POSTAL SERVICE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FELIPE S. QUINONES,

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Plaintiff,

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v.

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CASE NO. 1:13-cv-01553-DAD-EPG
JOINT STIPULATION TO CONTINUE
NON-EXPERT DISCOVERY AND
NON-DISPOSITIVE MOTIONS
DEADLINES; ORDER

MEGAN J. BRENNAN, POSTMASTER
GENERAL, UNITED STATES POSTAL
SERVICE,

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Defendant.

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Plaintiff Felipe S. Quinones (“Plaintiff”) and Defendant Megan J. Brennan, Postmaster

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General (“Defendant”), (“collectively “the parties”), stipulate, by and through the undersigned

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counsel, to extend the non-expert discovery and non-dispositive motions deadlines. The dates for

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filing dispositive motions, the pre-trial conference, and the trial date are not affected by this

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stipulation.

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This action arises from Plaintiff’s challenge to his removal from the position of a part time

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flexible clerk in the Lindsay Post Office alleging religious discrimination. Defendant disputes

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Plaintiff’s claims because it would be an undue hardship on the operations of the Lindsay Post Office

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to allow Plaintiff to have every Saturday off as there is only one other part time clerk to perform

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those duties on Saturdays.

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///

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JOINT STIPULATION TO CONTINUE NON-EXPERT DISCOVERY AND NON-DISPOSITIVE MOTIONS
DEADLINES; ORDER
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After engaging in extensive discovery including exchanging over 19,000 pages of documents

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and taking fifteen depositions, the parties agree to a short extension of the date by which to complete

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non-expert discovery in this case from April 11, 2016 to May 9, 2016, and a brief extension of the non-

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dispositive motions deadline from April 25, 2016 to May 23, 2016. The parties submit that this request

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is being made for good cause as the parties are scheduled for mediation with Honorable Enrique Romero

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on April 19, 2016. This brief extension of the discovery and non-dispositive motions deadlines will

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allow the parties to focus on a resolution before incurring additional fees and costs.

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In an effort to continue the good faith efforts by the parties to resolve this case and conserve
the parties and judicial resources until absolutely necessary, the parties stipulate and agree to continue
the following dates, and base it on the above-stated good cause.
Old Date

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New Date

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Close of Non Expert Discovery

April 11, 2016

May 9, 2016

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Non-Dispositive Motions

April 25, 2016

May 23, 2016

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Respectfully submitted,

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BENJAMIN B. WAGNER
UNITED STATES ATTORNEY

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Dated: April 11, 2016

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/s/ Alyson A. Berg
ALYSON A. BERG
Attorney for Defendant Megan A. Brennan
Postmaster General, United States Postal Service
CHURCH STATE COUNCIL

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(As authorized 04/11/16)

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Dated: April 11, 2016

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/s/ Alan J. Reinach
Alan J. Reinach
Jonathon Cherne
Attorneys for Plaintiff Felipe S. Quinones
SOTTILE & BALTAXE

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(As authorized 04/11/16)

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Dated: April 11, 2016

/s/ Timothy Sottile
Timothy Sottile
Attorneys for Plaintiff Felipe S. Quinones

JOINT STIPULATION TO CONTINUE NON-EXPERT DISCOVERY AND NON-DISPOSITIVE MOTIONS
DEADLINES; ORDER
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ORDER

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Having reviewed the stipulation submitted by the parties, and for good cause showing, the
above mentioned dates are continued as follows:

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Non-expert discovery cutoff:

May 9, 2016

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Non-dispositive motion deadline:

May 9, 2016

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All other deadlines in this case remain as set forth in the Order Adopting the Parties’ the Stipulation

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to Continue Pre-Trial and Trial Dates (ECF No. 52).

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IT IS SO ORDERED.
Dated:

April 13, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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JOINT STIPULATION TO CONTINUE NON-EXPERT DISCOVERY AND NON-DISPOSITIVE MOTIONS
DEADLINES; ORDER
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